Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Original order confirming GST demand was passed without opportunity of hearing. Appeal dismissed on limitation ground. Notification dated 02.11.2023 allows condonation of delay for appeals filed before 31.01.2024 against orders passed before 31.03.2023 u/ss 73/74 of GST Act. Impugned order passed on 20.07.2023, after 31.03.2023 cutoff date, hence notification inapplicable. Cited judgement deals with non-condonation of delay beyond statutory limitation period. Delay in filing appeal cannot be condoned beyond prescribed limitation under the Act. Petitions dismissed for lack of merit.
Original order confirming GST demand was passed without opportunity of hearing. Appeal dismissed on limitation ground. Notification dated 02.11.2023 allows condonation of delay for appeals filed before 31.01.2024 against orders passed before 31.03.2023 u/ss 73/74 of GST Act. Impugned order passed on 20.07.2023, after 31.03.2023 cutoff date, hence notification inapplicable. Cited judgement deals with non-condonation of delay beyond statutory limitation period. Delay in filing appeal cannot be condoned beyond prescribed limitation under the Act. Petitions dismissed for lack of merit.
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